Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in income tax for the period ending December 31, 1952 and the year 1953 in the amounts of $2,940.89 and $106,171.77, respectively. The years 1954 and 1955 are also involved because of net operating losses sustained in those years which petitioner is entitled to carry back to the years 1952 and 1953. The issues presented for our consideration are: (1) Whether...
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